
                                                    

                                       
                                       
                          Technical Support Document
                     Tribal Minor New Source Review Permit
                                    [DATE]


Permittee:		             Sac & Fox Tribe of the Mississippi in Iowa

Source: 		             Meskwaki Bingo Casino Hotel
		
Location: 		             1504 305[th] Street
			             Tama County, Iowa 52339

Source Technical Contact:	Jeff Kajer, Facility Director

ICIS Facility ID: 		#0700007000811121

Permit #:	                        R7-TMNSR-2023-001

Docket#: 		           EPA-R7-OAR-2019-0446

Pursuant to the provisions of Clean Air Act (CAA) sections 110(a) and 301(d) and the Code of Federal Regulations (CFR) title 40, sections 49.151-161, the United States Environmental Protection Agency (USEPA) Region 07 (EPA) is issuing a permit revision of a synthetic minor New Source Review (NSR) permit in Indian Country to the Sac & Fox Tribe of Mississippi in Iowa ("Permittee") for the Meskwaki Bingo Casino Hotel (MBCH) ("Source"), located near Tama, IA. This permit modification maintains enforceable restrictions on the potential to emit (PTE) of the Source's existing operations and/or authorizes modifications to the existing source, including replacement projects listed as:

 Laundry dryer replacement application submitted via letter October 21, 2020

 Heating, ventilation, and air conditioning (HVAC) unit upgrade application submitted via letter April 5, 2022

This Technical Support Document (TSD), supplied along with the issued modified permit, provides the EPA's analysis of the applications and describes the equipment that is authorized to be installed and/or operated, and the permit conditions that are revised in the synthetic minor NSR permit. 
                               Table of Contents

1.	Authority.......................................................................................................3
2.	Tribal Minor NSR Program Requirements................................................................3
3.	Source and Permit Information.............................................................................4
3.1	Source and Area Description................................................................................4
     3.2	Permit Action............................................................................................4
     3.3	Permit History ...........................................................................................5
4.	Public Participation..........................................................................................5
     4.1	Public Comment Period..................................................................................5
     4.2	Final Minor NSR Permit Action.......................................................................6
     4.3	Appeals to the Environmental Appeals Board (EAB)...............................................6
     4.4	Contact Information.....................................................................................6
5.	Registered/Existing/Authorized Emission-Generating Units..........................................6
     5.1	Emissions Units............................................................................................7
6.	New and Modifications to Emission-Generating Units and Activities................................7
     6.1	Additional Emissions Units ............................................................................7
7.	Summary of Emissions.......................................................................................7
     7.1	Emission Increases by Emission Unit.................................................................8
     7.2	Post-Modification Uncontrolled PTE..................................................................8
     7.3	Post-Modification Allowable Emissions..............................................................8
     7.4	Allowable Emission by Unit............................................................................8
8.	Control Technology Review for Proposed Modifications..............................................8
     8.1	Available Control Technologies for Engines (RICE) and Boilers...............      ............9
     8.2	Consideration of the Four Factors of the Control Technology Review...........................9
     8.3	Summary of Control Technology Review...........................................................10
9.	Air Quality Impact Analysis...............................................................................10
     9.1	Modeling Approach...................................................................................10
     9.2	AQIA Analysis Summary and Conclusion.........................................................11
10.	Listed Species-Related Requirements	....................................................................11
11.	Historic Properties-Related Requirements...............................................................12
12. 	Environmental Justice (EJ)................................................................................12
13.	Permit Content and Revisions	.............................................................................12
     13.1	Permit Content.........................................................................................13
     13.2	Other Permit Revisions...............................................................................14
APPENDIX A - Detailed list of emission units at the site
APPENDIX B - Detailed version of the emission calculations from NGCUs
APPENDIX C - Strikeout redline version of the 2019 issued original synthetic minor source permit showing revision areas.
 Authority

The CAA provides the EPA with broad authority to protect air resources throughout the nation, including air resources in Indian country. Title 40 of the Code of Federal Regulations, 49.151-165, establish a federal new source review program in Indian Country that, among other things, establishes (a) a preconstruction permitting program for new and modified minor stationary sources and minor modifications at major sources to meet the requirements of Section 110(a)(2)(C) of the Clean Air Act; (b) a mechanism for otherwise major sources (including major sources of hazardous air pollutants) to voluntarily accept restrictions on potential to emit to become synthetic minor sources; and (c) a mechanism for case-by-case maximum achievable control technology determinations for those major sources of HAPs subject to such determinations under Section 112(g)(2) of the Clean Air Act. In 2011, the EPA established the Tribal Minor NSR Program as part of a FIP under the CAA for Indian country, through the Tribal NSR Rule. The EPA has followed the Tribal Minor NSR Program in this permit action.


 Tribal Minor NSR Program Requirements

The Tribal Minor NSR Program (40 CFR 49.151-165) is applicable to owners and operators of sources located, or planning to locate, in Indian reservations, and in other areas of Indian country where no EPA-approved tribal air permit program is in place and where an Indian tribe or the EPA has demonstrated that the tribe has jurisdiction. MBCH is located on the Indian reservation and there is no EPA-approved tribal CAA permitting program in place for this area.


The Tribal Minor NSR Program requires owners and operators of certain new and modified sources of air pollution in Indian country to obtain a minor NSR permit prior to constructing or modifying a source. This preconstruction permitting program is triggered for new or modified sources based on potential increases in air pollutants according to the applicability criteria in 40 CFR 49.153. Generally, source owners and operators first determine whether their new or modified source is subject to the CAA major NSR permitting program (pursuant to 40 CFR 52.21 for areas designated as attainment/unclassifiable for the National Ambient Air Quality Standards (NAAQS)) and/or 40 CFR 49.166 through 49.175 for areas designated as nonattainment for the NAAQS). The applicable permitting program is determined individually for each NSR pollutant. When a pollutant is not subject to major NSR review, the owner and operator must evaluate whether the Tribal Minor NSR Program applies. Additionally, the Tribal Minor NSR Program allows existing major sources in Indian country to apply for a synthetic minor source permit to limit their PTE below title V and NSR major source permitting thresholds. See 40 CFR 49.158. Restrictions on the PTE of a synthetic minor source are required to be enforceable as a practicable matter, as defined in 40 CFR 49.152.


 Source and Permit Information

3.1	Source and Area Description

49.154(a)(2)(i)  -  Identifying Information related to this permitting action

 Source Address
Meskwaki Bingo Casino Hotel (MBCH)
1504 305[th] Street
Tama, IA 52339

 Permit Contact Address
Jeff Kajer
Facility Director
Tel: (641) 484-1558
Cell: (641) 750-4560
Fax: 641-484-1434
 Email: jkajer@meskwaki.com

 Source Location Mapping
Latitude: 41 59' 42"; Longitude 92 40' 07"
Section: 13 (SW1/4 quarter section); Township 83N; Range 16W

The Sac & Fox Tribe of the Mississippi in Iowa owns and operates the Meskwaki Bingo Casino Hotel (MBCH).  The MBCH facility includes the operation of six diesel-fired RICEs (also referred to as RICE(s), Reciprocating Internal Combustion Engine(s)) and one natural gas fired RICE. Four of the diesel-fired RICE  are non-emergency  RICE used for peak load management, storm avoidance, and emergency backup power. Two diesel fired RICE are used as backup units only. 

Each of the diesel RICE at the MBCH facility is equipped with a sub-base diesel fuel tank. The facility also operates two (2) 500-gallon yard tanks for fueling gasoline or diesel operated vehicles and equipment on the property. This permit incorporates the replacement of two existing 500-gallon yard storage tanks with two new double-wall 500-gallon yard storage tanks with interstitial leak gauge monitors.

The MBCH facility includes several existing natural gas combustion units (NGCUs) consisting of boilers, furnaces, water heaters used for space heating and water heating at the hotel, casino, and other buildings on the MBCH property.  There are also collections of units associated with the cooking of food within the Casino. Additionally, the MBCH facility includes four (4) induced draft cooling towers that provide comfort cooling for the MBCH buildings.

Air pollutants at this facility include nitrogen oxides (NOx), carbon monoxide (CO), sulfur oxides (SOx), volatile organic compounds (VOC), particulate matter (PM), PM with aerodynamic diameter equal to or less than 10 microns (PM10), and PM with aerodynamic diameter equal to or less than 2.5 microns (PM2.5), hazardous air pollutants (HAP), and greenhouse gases (GHG).  The uncontrolled potential emissions for NOx are above major source thresholds established under the Prevention of Significant Deterioration (PSD) permitting program regulations and the federal operating permit program regulations at 40 CFR Part 71 (Title V or Part 71).



3.2	Permit Action

The Tribal Minor NSR Program (40 CFR 49.151-165) requires certain new and modified minor and major sources in Indian country to apply for and obtain a permit prior to construction or modification. Additionally, the Rule provides a mechanism for new and existing sources to establish a synthetic minor limit on their potential to emit (PTE). Synthetic minor permit limits are voluntary, enforceable restrictions on a source's operations that reduce the source's PTE. Such limits can then be used to avoid being subject to other Clean Air Act requirements such as the major NSR program or the title V operating permit program. 

After initial consultation with the EPA, the MBCH facility applied for permit modification for their existing synthetic minor source permit issued on Sept 10, 2019, Permit Number R7-TMNSR-2019-002. MBCH received a synthetic minor source permit because there was federally enforceable NOx emission permit limit to keep the emissions below major source Title V thresholds. The permitting action associated with R7-TMNSR-2023-001 includes the following: 

 Incorporate and allow these modification projects  -  Laundry dryer replacement and HVAC unit upgrades.

 Revise permit limits and equations, as needed, in order to account for various types of natural gas combustion units (NGCUs) with varying emission factors. Specifically, the permit needed to account for the emissions from the natural gas-fired emergency RICE. The NGCUs are equipped with designated gas meters, hence, changes in permit limit equations were necessary to account for multiple emission factors. 

 The original synthetic minor source permit language (including but not limited to emission unit nomenclature) were revised to make the permit more precise/specific to enforceable permit limits, flexible to incorporate future minor changes at the site, and more robust requirements overall. Also, for the revised and appropriate NOx emission calculation formulae, any additional hourly permit limit for any emission limit is redundant. Hence, those hourly limits were removed as a result of this permitting action.

 Incorporated the revised gas meter #s for each location below, per MBCH email communication, dated 09 March 2023:
                  
Location of the NGCUs at the site
Gas Meter #s
East Building/Gaming Commissions
450057898
Warehouse
96216023
North Tower Hotel (including EU-EG-09, new emergency RICE)
1343357
Central Plant, Casino, RV
9743221

Since MBCH is an existing synthetic minor source, the new equipment will be subject to review as a minor NSR modification under the Tribal Minor NSR program. The Source's existing operations are described below in Section 3 and the proposed modifications are described in Section 4. The addition of the new equipment will not trigger major NSR or PSD requirements because, as explained in Section 6 below, (1) the existing source is not a major source and (2) the addition of the new equipment will not constitute a major source in and of itself under the applicable regulations.  The strikeout red line version of the original synthetic minor source permit, showing the revised areas are given in Appendix C of this permit. 

Tribal Consultation for Permit Modification: As part of EPA Region 7's federal program implementation and oversight responsibilities, EPA Region 7's policy is to consult on a government-to-government basis with federally recognized tribal governments when EPA actions and decisions may affect tribal interests. EPA Region 7 initiated a formal consultation with the Sac & Fox Tribe of the Mississippi in Iowa (tribal leadership council) regarding the issuance of this synthetic minor source permit for the MBCH via written correspondence dated May 8, 2023, specifically to discuss the current permit modification details, similar to what was done in 2019, during the issuance of the initial synthetic minor source permit. The tribal leadership did not accept our offer to consult. . Hence, the draft permit was put on public notice per permitting procedures. 

Separately, draft permit documents were shared with MBCH for comments, which were received on May 10, 2023. These edits and suggestions were incorporated as relevant.


 Permit History 

Table 1: Permit Revision History
                          Application Submission Date
                             Public Comment Period
                             Tribal Consultation 
                           Letter Notification Date
                               Permit Issue Date
                             Description/Category
                                 Docket Number
Application Submitted in 3-14-2016; Complete submission: 6-1-2016
Aug 1  -  Sep 1, 2019
July 19, 2019
Sept 10, 2019
Initial Synthetic Minor Permit 
EPA-R07-OAR-2019-0046
Oct. 21, 2020
(Laundry Unit Replacement Project);
April 5, 2022
(HVAC Unit Replacement Project)
Aug 1-Sep 1, 2023
May 8, 2023
TBD
Modification of the Initial Synthetic Minor Permit, issued on Sept 10, 2019.
EPA-R07-OAR-2019-0046


 Public Participation
                     
4.1	Public Comment Period

In accordance with 40 CFR 49.157, the EPA must provide public notice and a 30-day public comment period to ensure that the affected community and the general public have reasonable access to the application and draft permit information. 

The draft permit, this TSD, and all other supporting materials for the draft permit are available for review at either of the following locations (physical address): 

Location 1: 
      EPA Region 07
      Air and Radiation Division
            11201 Renner Boulevard
      Lenexa, KS 66219
      Contact: Rumela Bhadra (Permit Engineer)
      Phone: (913) 551-7366
      Email: bhadra.rumela@epa.gov
	
Location 2
	Director's Office
	Tama Public Library
	401 Siegel Street,
	Tama, IA 52339
	Phone: (641) 484-4484
	Email: tamalibrary@tama.lib.ia.us 


The administrative record for this action is available at www.regulations.gov under docket ID number EPA-R07-OAR-2019-0046 and is available for review at our office Monday through Friday from 9:00 a.m. to 4:00 p.m. (excluding federal holidays). A link to the docket is also included on our website at www.epa.gov/caa-permitting/tribal-nsr-permits-region-07

Any person may submit written comments on the draft permit or the EPA's finding under this action pursuant to section 106 of the National Historic Preservation Act during the public comment period. These comments must raise any reasonably ascertainable issues with supporting arguments by the close of the public comment period. Anyone may request a public hearing pursuant to 40 CFR 49.157(c) prior to the end of the public comment period. A request for public hearing must include the nature of the issues to be raised at the hearing. EPA will base its decision on whether a hearing will be held upon the showing of a significant degree of public interest. EPA may also hold a public hearing at its discretion. EPA will provide at least 30 days' notice prior to the date of the hearing. The public comment period will be extended to the close of any public hearing. The EPA accepts comments and requests for a public hearing by mail to the EPA address listed above, on www.regulations.gov under docket ID number EPA-R07-OAR-2019-0046, and via email to bhadra.rumela@epa.gov. Please address comments with the subject "Comments on Draft Permit for the Meskwaki Bingo Casino Hotel (MBCH)."

4.2	Final Minor NSR Permit Action

In accordance with 40 CFR 49.159, a final permit becomes effective 30 days after the service of notice of the decision, unless: (1) a later effective date is specified in the permit;  (2) appeal of the final permit is made as detailed in the next section; or (3) the permitting authority makes the permit effective immediately upon issuance, which it can do only if no comments requested a change in the draft permit or a denial of the permit. We will send notice of the final permit action to any individual who commented on the draft permit during the public comment period. As required in 40 CFR 49.159, Region 07 will notify the Permittee in writing of the final decision and will provide adequate public notice of the final permit decision to ensure that the affected community, general public and any individuals who commented on the draft permit have reasonable access to the decision and supporting materials. In addition, anyone may request a copy of the final permit from the contact for this action or through the list of minor NSR permit actions on our website. See the contact information provided below.

4.3	Appeals to the Environmental Appeals Board (EAB)

In accordance with 40 CFR 49.159, within 30 days after a final permit decision has been issued, any person who filed comments on the draft permit or participated in the public hearing may petition the EAB to review any condition of the permit decision. The 30-day period within which a person may request review under this section begins when the Region has fulfilled the notice requirements for the final permit decision. A petition to the EAB for review of the final permit decision is, under section 307(b) of the Act, a prerequisite to seeking judicial review of the final agency action. For purposes of judicial review, final agency action occurs when the EPA denies or issues a final permit and agency review procedures are exhausted.

The contact information for this permitting action is:

      Rumela Bhadra
      Tribal Permitting Coordinator
      Email: bhadra.rumela@epa.gov 
      Phone: (913) 551-7366
      EPA toll-free general information line: 1-800-223-0425

EPA Region 07 maintains a list of its Tribal Minor NSR permitting actions on our website at https://www.epa.gov/caa-permitting/tribal-air-permitting-region-7 


 Registered/Existing/Authorized Emission-Generating Units and Activities Under Permit  

5.1	 Emission Units

Per 40 CFR 49.154(a)(2)(ii) Source processes and products: The source is a casino and hotel that utilizes several emission units including multiple diesel and natural gas-fired RICE. Some of the RICE are designated as emergency, which means that they are only used to supply electricity during power outages and limited hours of operation for other purposes per federal rules for National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Stationary RICE found at 40 CFR Part 63 Subpart ZZZZ (MACT Subpart ZZZZ) and for National Standards of Performance (NSPS) for RICE found at 40 CFR Part 60 Subpart IIII (relevant for diesel fired RICE) or Subpart JJJJ (relevant for natural gas fired RICE), as applicable. Please refer to Appendix A (of this document), Table 1.0 & 1.1 for the detailed list of RICE at the site, post modification.  EU-EG-02, EU-EG-03, EU-EG-04, and EU-EG--05R are diesel fired RICE that have a maximum 300 hours per year operational capacity and are used to provide electricity during peak electricity demand periods. The 300 hour per year limit is federally enforceable. Also, for the three emergency RICEs (EU-EG-06, EU-EG-07, and EU-EG09, collectively identified as EU-EMERG in the synthetic minor permit), two of the RICEs are diesel fired while the third one is natural gas fired. The maximum potential emission calculations (worst case scenario) for EU-EMERG are calculated based on 500 hours of operation per year. 

The facility has several natural gas combustion units (NGCUs) used for space heating, cooking, and other activities in the hotel arena. Please refer to Appendix A, Table 2.0 for the details list of NGCUs at the site, post modification, including the identification of the natural gas supply meter associated with each unit.


 New and Modifications to Emission-Generating Units and Activities 

6.1	Additional/Affected Emission Units

Per 49.154(a)(2)(iii) the affected emissions units related to the new projects are described below.

 Project 1 - Laundry Dryer Replacements: 

MBCH proposes to replace 4 laundry dryers (3 dryers with a 0.395 million British thermal units per hour (MMBtu/hr) rated capacity and 1 with a 0.165 MMBtu/hr rated capacity) and 1 sheet press @ 0.98 MMBtu/hr with 3 new dryers (each with a 0.395 MMBtu/hr rated capacity) and 1 compact unit rated at 0.481 MMBtu/hr. Washers related to this project are not emission units per the application because they are electric. The incoming dryers will be natural gas fired. The total heat capacity of the units being removed is 2.235 MMBtu/hr vs. the units being installed is 1.66 MMBtu/hr. Thus, there is a net decrease in the facility rated capacity post project. 

                                     EU-ID
                                  Description
                                   Location
                                Outgoing Units
EU-NG-34
Dryer 1, Raytheon, Model no. JT170FG, natural gas fired, @ 0.395 MMBtu/hr
Hotel Laundry
EU-NG-35
Dryer 2, Huebsch, Model no. HT170NRQF6G1W01, natural gas fired, @ 0.395 MMBtu/hr
Hotel Laundry
EU-NG-36
Dryer 3, Raytheon, Model no. JT170FG, natural gas fired, @ 0.30 MMBtu/hr
Hotel Laundry
EU-NG-37
Dryer 4, Raytheon, Model no. JT170FG, natural gas fired, @ 0.165 MMBtu/hr
Hotel Laundry
EU-NG-38
Sheet Press, Chicago, Model no. CROSSTAR36-120, natural gas fired, @ 0.98 MMBtu/hr
Hotel Laundry
                                Incoming Units
EU-NG-92
Dryer 1, Continental Girbau, Model no. CG165-175, natural gas fired, @ 0.395 MMBtu/hr
Hotel Laundry
EU-NG-93
Dryer 2, Continental Girbau, Model no. CG165-175, natural gas fired, @ 0.395 MMBtu/hr
Hotel Laundry
EU-NG-94
Dryer 3, Continental Girbau, Model no. CG165-175, natural gas fired, @ 0.395 MMBtu/hr
Hotel Laundry
EU-NG-95
Compact Sheet Press, Continental Girbau, Model no. CP32130S, natural gas fired, @ 0.481 MMBtu/hr
Hotel Laundry
         
   Project 2  -  HVAC/Furnace Replacements:
  
The casino proposes to replace 12 emission units (at total capacity of 1.27 MMBtu/hr) with 12 new emissions units (at the total capacity of 3.23 MMBTU/hr.  The emission units being removed consist of one propane fired emergency RICE and natural gas fired HVAC furnaces. The new emergency RICE and furnaces are also natural gas fired. The emergency RICE is subject to MACT Subpart ZZZZ and or NSPS Subpart JJJJ. PTE for emergency RICEs is based on 500 hours/yr, which is the worst-case scenario for emergency RICEs.

                                     EU ID
                                  Description
                                   Location
                                Outgoing Units
EU-EG-08
Kohler RMY-QS2 Emergency RICE, propane fuel, 13 HP (10 KW) @ 0.27 MMBTU/hr. MACT Subpart ZZZZ
North Tower rooftop
EU-NG-72
Lennox Furnace, Model no. GCS16-G53-125-5Y, heating/HVAC unit, @ 0.125 MMBTU/hr, natural gas fired.
Roof top Unit
EU-NG-73
Lennox Furnace, Model no. GCS16-G53-125-5Y, heating/HVAC, @ 0.125 MMBTU/hr, natural gas fired
Roof top Unit
EU-NG-74
Lennox Furnace, Model no. GCS16-G53-125-5Y, heating/HVAC, @ 0.125 MMBTU/hr, natural gas fired
Roof top Unit
EU-NG-75
Lennox Furnace, Model no. GCS16-G53-125-5Y, heating/HVAC, @ 0.125 MMBTU/hr, natural gas fired
Roof top Unit
EU-NG-76
Lennox Furnace, Model no. GSR2104-50-1, heating/HVAC, @ 0.05 MMBTU/hr, natural gas fired
2[nd] Floor South
EU-NG-77
Lennox, Model no. GSR2104-5-100-1, heating/HVAC, @ 0.1 MMBTU/hr, natural gas fired
2[nd] Floor South 
EU-NG-78
Lennox Furnace, Model no. G21Q4-60-1, heating/HVAC, @ 0.06 MMBTU/hr, natural gas fired
2[nd] Floor South 
EU-NG-79
Lennox Furnace, Model no. G26Q4/5-75-6, heating/HVAC, @ 0.076 MMBTU/hr, natural gas fired
1st Floor North
EU-NG-80
Lennox Furnace, Model no. GSR21Q3-50-1, heating/HVAC, @ 0.05 MMBTU/hr, natural gas fired
2[nd] Floor West
EU-NG-81
Lennox Furnace, Model no. GSR21Q4/5-80-1, heating/HVAC, @ 0.08 MMBTU/hr, natural gas fired
2[nd] Floor North
EU-NG-82
Lennox Furnace, Model no. G21Q4-60-1, heating/HVAC, @ 0.06 MMBTU/hr, natural gas fired
1[st] Floor North
                                Incoming Units
EU-EG-09
Kohler RICE, emergency RICE, natural gas fired, Model No. KG150, 150 KW, @ 1.919 MMBtu/hr
North Tower
EU-NG-96
Rheem Furnace/HVAC heating, Model no. RGEDZ5090ACB20BAA, natural gas fired, @ 0.205 MMBtu/hr
NE Roof Top Unit
EU-NG-97
Rheem Furnace/HVAC heating, Model no. RGEDZ5090ACB20BAA, natural gas fired, @ 0.205 MMBtu/hr
NE Roof Top Unit
EU-NG-98
Rheem Furnace/HVAC heating, Model no. RGEDZ5090ACB20BAA, natural gas fired, @ 0.205 MMBtu/hr
NE Roof Top Unit
EU-NG-99
Rheem Furnace/HVAC heating, Model no. RGEDZ5090ACB20BAA, natural gas fired, @ 0.205 MMBtu/hr
NE Roof Top Unit
EU-NG-100
Rheem Furnace/HVAC heating, Model no. W95TC06001317MSA, natural gas fired, @0.056MMBtu/hr
SE Roof Top Unit
EU-NG-101
Rheem Furnace/HVAC heating, Model no. W95TC06001317MSA, natural gas fired, @0.098 MMBtu/hr
SW 2[nd] Floor 
EU-NG-102
Daikin Furnace/HVAC heating, Model no. DM96VC0804CNAA, natural gas fired, @0.08 MMBtu/hr
Print Shop S. 2[nd] Floor
EU-NG-103
Rheem Furnace/HVAC heating, Model no. W95TC06001317MSA, natural gas fired, @0.07 MMBtu/hr
NE 1[st] Floor
EU-NG-104
Rheem Furnace/HVAC heating, Model no. W95TC06001317MSA, natural gas fired, @0.066 MMBtu/hr
NW 2[nd] Floor
EU-NG-105
Rheem Furnace/HVAC heating, Model no. W95TC06001317MSA, natural gas fired, @0.07 MMBtu/hr
NW 2[nd] Floor
EU-NG-106
Rheem Furnace/HVAC heating, Model no W95TC06001317MSA, natural gas fired, @0.056 MMBtu/hr
NE 1[st] Floor

The facility was issued a synthetic minor NSR permit in 2019 and is requesting to incorporate the above two projects, which by themselves would have been below the minor source thresholds for permitting modifications. Additionally, it is noted in the permit that per 40 CFR 49.153(c), some of the emissions units at the site (existing), are listed as exempt units. However, those units are not part of the current replacement projects.

   Summary of Emissions

7.1	Emission Increases by Emission Unit

Emissions of New Source Review (NSR) pollutants from the proposed projects:

Project 1  -  Laundry Dryer Replacements: Total rated capacity of the new incoming units is 1.66 MMBtu/hr. All units are natural gas fired. The emission factors from these natural gas-fired units were taken from AP-42 Table 1.4-1, and 1.4-2 for criteria pollutants, and Table 1.4-3 and 1.4-4 for HAPs. The potential emissions from these units (refer to Section 6.1 of this document), were calculated at 8760 hours as the maximum worst scenario. 


Pollutants
Allowable Potential-to-emit (PTE) from new emission units (Tons per year, tpy)*
            NSR Minor Source Thresholds for Attainment areas (tpy)
                         Per Table 1 of 40 CFR 49.153
Carbon Monoxide (CO)
                                     0.60
                                      10
Oxides of Nitrogen (NOx)
                                     0.72
                                      10
Particulate Matter (PM)
                                     0.05
                                       5
Particulate Matter less than 10 microns (PM10)
                                     0.05
                                      10
Particulate Matter less than 10 microns (PM2.5)
                                     0.05
                                       5
Sulfur Dioxide (SO2)
                                 4.29 X 10[-3]
                                      10
Volatile Organic Compounds (VOC)
                                     0.04
                                       5
Hazardous Air Pollutant (HAPs) - combined
                                 5.90 X 10[-4]
                                      NA
Benzene
                                   1.50E-05
                                      NA
Formaldehyde 
                                   5.37E-04
                                      NA
CO2eq   
                                    863.87
                                      NA
Pb
                                  Negligible
                                       3
*Allowable PTE includes all enforceable permit limits (hourly, operational capacity, etc.) while calculating the emissions, if applicable for those units. NA means not applicable. 



Project 2  -  HVAC Unit Upgrades: Total rated capacity of the new natural gas fired units is 3.235 MMBtu/hr, this includes a 1.919 MMBtu/hr natural gas fired emergency RICE with 150 KW rating. The potential emissions from this project (refer to Section 6.1 of this document), were calculated using factors from AP-42 Table 1.4-1 and 1.4-2 for natural gas combustion units for criteria pollutants, and Table 1.4-3 and 1.4-4 for HAPs. Additionally, AP-42 Table 3.2-3 and 40 CFR 98 Table C-2 were referred to for natural gas fired RICE emission factors. Potential emissions from emergency RICE in this project were calculated based on 500 hours/yr, while other units were based 8760 hours/yr, as the maximum worst-case scenario. 
         
Pollutants
Allowable Potential-to-emit (PTE) from new emission units (Tons per year, tpy)
            NSR Minor Source Thresholds for Attainment areas (tpy)
                         Per Table 1 of 40 CFR 49.153
CO
                                     2.14
                                     10.0
NOx
                                     1.48
                                     10.0
PM
                                     0.04
                                      5.0
PM10
                                     0.04
                                     10.0
PM2.5
                                     0.04
                                      5.0
SO2
                                   2.80E-03
                                     10.0
VOC
                                     0.04
                                      5.0
HAPs- combined
                                   4.25E-02
                                      NA
Benzene
                                   7.67E-04
                                      NA
Formaldehyde
                                   1.01E-02
                                      NA
CO2eq
                                    558.75
                                      NA
Pb
                                  Negligible
                                      3.0
         
There are no quantifiable fugitive emissions from the above laundry and HVAC replacement projects. This was also stated in the modification application letters.
         
Emission Changes from Units Not Described under Projects 1 & 2 (Other units):  Emission units that are not listed under Projects 1 and 2 are not being changed or modified. Hence, those "other units" did not change their emission levels and are the same as in the 2019 permit document and therefore it is not listed in this document since this TSD is specific to modification request for Projects 1 and 2.

Minor NSR Thresholds: Neither project's emission changes were large enough to trigger the requirement for a construction permit. Combining the emission increase from both projects is still below the thresholds in Table 1 of 40 CFR 49.153 that would require a construction permit. Although the projects do not require a minor NSR permit the synthetic minor permit needs to be revised to keep the emission limits technically accurate. The threshold values are given in the above tables. 
         
         
7.2	   Post-Modification Uncontrolled PTE

As summarized in the Table below, the MBCH's uncontrolled PTE would exceed the Title V major source thresholds for NOx, i.e., above 100 tpy. The potential emissions for all the diesel fired RICE units, designated as EU-EG-02, EU-EG-03, EU-EG-04, and EU-EG-05R, were calculated based on 8760 hours/year, while for the emergency RICE (EU-EMERG; EU-EG-06, EU-EG-07, EU-EG09) the PTE was calculated based on 500 hours/yr, which is the worst-case scenario estimate for emergency RICEs

Pollutants
                            Uncontrolled Emissions
                             (Tons per year, tpy)*
Carbon Monoxide (CO)
                                     77.94
Oxides of Nitrogen (NOx)
                                    802.51
Particulate Matter (PM)
                                     17.75
Particulate Matter less than 10 microns (PM10)
                                     14.17
Particulate Matter less than 10 microns (PM2.5)
                                     11.70
Sulfur Dioxide (SO2)
                                     0.55
Volatile Organic Compounds (VOC)
                                     21.28
Hazardous Air Pollutant (HAPs) - combined
                                     1.58
Benzene
                                     0.28
Formaldehyde
                                     0.06
CO2eq
                                   85,998.46
Pb
                                  Negligible.
         *Uncontrolled emissions are calculated based on 8760 hours/yr for all RICE and NGCUs located at the site. 
         
         
7.3	Post-Modification Allowable Emissions

Pursuant to 40 CFR 49.158, the MBCH was issued a permit on Sept. 1, 2019, which created enforceable operating and emission limitations that limited the Source's facility-wide PTE for NOx at 95 tpy, thereby keeping the emissions below the major source threshold of 100 tpy. The uncontrolled emissions from all the units at the site were above major source threshold (Title V) for NOx, hence, federally enforceable permit limits were needed to maintain the synthetic minor source status. Although the changes to the MBCH associated with this project would not have required a permit, the permit needed to be revised to keep the emission limits technically accurate.
    
        Referring to Section II (A) and (B) of the associated DRAFT permit (along with this TSD), it is stated that all active RICE units (non-natural gas fired units) are capped (restricted) at 74 tpy total emission for NOx, while all natural gas combustion units (NGCUs) are capped at 21 tpy. It should be noted that all NGCUs includes any active natural gas fired RICE being routed to the gas meters at the site. Hence, in accordance with 40 CFR 49.154(a)(2)(vi) post project#1 and #2 modifications, MBCH will continue to collect information, and regulate the fuel usage and operating schedules in order to restrict the facility wide NOx emissions to 95 tpy or below, thereby maintaining the synthetic minor source status.

To calculate the maximum allowable emissions in the Table below, for the diesel fired RICE, designated as EU-EG-02, EU-EG-03, EU-EG-04, and EU-EG-05 there is a maximum peaking hour limit of 300 hours/year, while the emergency RICE (EU-EMERG; EU-EG-06, EU-EG-07, EU-EG09) is calculated based on 500 hours/yr, which is worst case estimate for emergency RICEs Additionally, the emergency RICE  are subject to the regulations for emergency RICE in NSPS Subpart IIII and JJJJ which limits the operating hours to 100 hours per year for defined non-emergency purposes (no limit of defined "emergency purposes) and requires the owner or operator to install a non-resettable hour meter on each RICE. 

Separately, MBCH has some natural gas cooking units at six locations, designated as EU-NG-C1 through EU-NG-C6. These units are categorized as "exempt units" because they meet the criteria of cooking food, except wholesale businesses for cooking and selling food per 40 CFR 49.153(c)(3).
However, the PTE from these units cannot be excluded from final facility wide post project emissions, based on the EPA's interpretation of the Tribal NSR permitting rules.  

Exempt Units: Separately, there are a collection of natural gas fired cooking units, that were considered to be "exempt units" per 40 CFR 49.153(c) regulation guidelines but cannot be excluded from the facility wide emission calculations in determining if the facility is major. This rationale is based on the EPA's interpretation of the term major source. However, many future modifications related to exempt units, can be undertaken by MBCH without approval from EPA R7, because exempt units are not subject to tribal NSR permitting. The permit would only need modifications where the change would make the emission calculations incorrect.

Also, it should be noted that MBCH has a collection of boilers and furnaces that are used for space heating, in the locations - Casino Central Plant, Casino Old Mech., Hotel North Tower, East building, Warehouse/Rec, and Roof Top units in East Building; that collectively are rated > 10 MMBtu/hr facility wide, hence, 40 CFR 40.153(c)(11)(iii) exemption criteria cannot be applied. More details on the exempt and non-exempt unit categorization of all-natural gas fired units at MBCH, refer to Section I (B) (2) of the attached revised draft permit, issued with this TSD.




Pollutants
                          Post Modification Emissions
                             (Tons per year, tpy)
                                       
                           All facility wide units 
               All facility wide units without the Exempt Units
Carbon Monoxide (CO)
                                     23.43
                                     20.65
Oxides of Nitrogen (NOx)
                                     53.47
                                     50.16
Particulate Matter (PM)
                                     8.11
                                     7.86
Particulate Matter less than 10 microns (PM10)
                                     6.98
                                     6.73
Particulate Matter less than 10 microns (PM2.5)
                                     2.28
                                     2.03
Sulfur Dioxide (SO2)
                                     0.15
                                     0.13
Volatile Organic Compounds (VOC)
                                     1.75
                                     1.57
Hazardous Air Pollutant (HAPs) - combined
                                     0.17
                                     0.10
Benzene
                                     0.01
                                     0.01
Formaldehyde
                                     0.03
                                     0.03
Pb
                                  Negligible
                                  Negligible
CO2eq
                                   29,534.89
                                   25,556.89

7.4	Allowable Emission Limits 

Per Section II. (A) of the original synthetic minor source permit (R7-TMNSR-2019-002), all the diesel fired RICE collectively are allowed and permitted to emit no more than 74 tons of NOx based on 12-month rolling emissions totals and per Section II (B) of the permit all the NGCUs (including the natural gas fire emergency RICE) collectively are allowed and permitted to emit no more than 21 tons of NOx based on 12-month rolling emissions. 

Compliance with these allowable NOx limits for RICE and NGCUs is demonstrated by following the below compliance equations in order to calculate NOx emissions each 12 month rolling totals.

The compliance formula for all diesel fired RICE - Per Section II(A)(1).vii of 2019 Permit:

Within fifteen days of the end of each month, the permittee shall calculate and record the NOx emissions from all RICE(s), using the following equation:

     NOx Emissions (tons/month) based on hours of operation = 
     
     [ (# Hours EU-EG-02 * 48.9 lb/hr) + 
     (# Hours EU-EG-03 * 44.9 lb/hr) + 
     (# Hours EU-EG-04 * 71.9 lb/hr) + 
     (# Hours EU-EG-05R * 4.06 lb/hr) + 
     (# Hours EU-EG-06 * 6.42 lb/hr) + 
     (# Hours EU-EG-07 * 6.42 lb/hr) ] * 1.1 * 1 ton/2,000 lbs.
     
     Where: 
     
     EU-EG-06 and EU-EG-07 are designated as emergency RICE (diesel fired)
     
     # Hours refers to the actual number of hours that a specific RICE  is operated for the month.
     
     lb/hr factors associated with EU-EG-02, EU-EG-03, EU-EG-04, and EU-EG-05R are emission factors derived from RICE specifications provided in the January 2019 permit application. 
     
     lb/hr factors associated with EU-EG-06 and EU-EG-07 are emission factors derived from AP-42, Chapter 3, Table 3.3-1.
     
     1.1 is a safety factor that provides a 10% increase to each of the lb/hr emission factors in the equation to account for potential differences in emissions between the stack tested RICEs, used to derive the lb/hr emission factors and the permitted RICEs.
     
Previous Compliance Formula for all NGCUs - Per Section II(B)(1).iv of the 2019 Permit:

Within fifteen days of the end of each month, the permittee shall calculate and record the NOx emissions from all NGCUs, using the following equation:

     NOx Emissions (tons/month) based on fuel usage = 
     
         100 lbs./MMscf * FNG (MMscf) * 1 ton/2,000 lbs.
     
     Where
     
     100 lbs./MMscf is the NOx emission factor for uncontrolled Small Boilers (<100 MMBtu/hr) from AP-42, Table 1.4-1.

     FNG = total amount of natural gas (MMscf/month) consumed by all NGCU determined by summing the amounts derived from each of the four natural gas flow meters. Refer to Table 2 in this TSD for the detailed list of all NGCUs.
     
As explained in next Section 7.5, "Rationale for Modification of Initial Synthetic Minor Source Permit", the NOx emission compliance formula from all NGCUs will be modified during this current permitting action. The most updated compliance formula from NGCUs is given in Section 7.5 (next section of this document) and in the revised permit document. Hence, after these enforceable limitations are incorporated into the permit, the Source will maintain its status as a synthetic minor source subject to CAA permitting under 40 CFR 49.158. 

7.5   Rationale for Modification of the Initial Synthetic Minor Source Permit (issued on Sept 10, 2019) for Laundry and HVAC Upgrade Projects.

The project description and the emission details for project R7-TMNSR-2023-001 are included in Sections 1.1 through 1.5 in this document. Based on the applicability guidelines in 40 CFR 49.153(a)(1)(ii) for modification at an existing source, specifically for a modification at an existing synthetic minor source (calculations guidelines beginning from Step 2), these projects are below the criteria for minor source permitting. Furthermore, the PTE values of Projects 1 and 2 described earlier are below the minor NSR thresholds in Table 1 per 40 CFR 49.153 and hence, following the Step 2 and Step 3, referenced in 40 CFR 49.153(a)(1)(ii), these proposed modifications are not subject to the pre-construction NSR program.

However, Section II. (B) of the 2019 original permit (R7-TMNSR-2019-002) contains a key equation related to the NOx federally enforceable permit limit from all NGCUs that is no longer relevant once we incorporate the HVAC/heating project replacement. Specifically, that equation contains 100 lb/MMScf (lbs/million standard cubic feet) as the emission factor for boilers and furnace type units, from AP-42, Chap 1.4. For the new emergency natural gas fired RICE (part of the HVAC project), routed to the gas meter #1343357 along with other existing natural gas fired boilers/furnace, this equation is not appropriate. The emission factor stated is not appropriate for the new emergency RICE. Hence, this equation needs revision to accommodate the combustion of natural gas from various emissions units including boilers, furnaces, and RICE. Therefore, the revision of this key equation related to the NOx permit limit warrants a permit modification, which includes a public participation process.

In summary, the compliance formula for RICE in Section II (A)(2) of permit R7-TMNSR-2019-002 is still appropriate. However, the compliance formula for NGCUs (all units including the new natural gas fired RICE) in Section II (B)(2) of R7-TMNSR-2019-002 is no longer valid after incorporating Projects 1 and 2, through the current permitting action. Thus, the compliance formula in Section II(B)(2) was modified as follows:

Emission Limit: 

All NGCUs (included the natural gas fire emergency RICE) collectively are allowed and permitted to emit no more than 21 tons of NOx based on 12-month rolling emissions.


Modified Compliance Formula for All NGCUs routed to Gas Meters at the Site:

Within fifteen days of the end of each month, the permittee shall calculate and record the NOx emissions from all NGCUs routed to the existing gas meters, using the equation (1) and sub equations 1(a) and 1(b):


NOx Emissions (tons/month) (all NGCUs) = 

[NOx emissions from natural gas fired RICE] + [NOx emissions from natural gas fired Boilers/HVAC/Heating] (tons/month)......................................................................................................................... (1)


Where, 
NOx emissions from natural gas fired RICEs tons/month= i=1nEFRICEeq lbMMScfx Fuel ConsumptionRICEMMScfhrxHours of OperationRICE hrx(1 ton2000)..........................(1a)

                             
   n = no. of RICE at the site connected to natural gas meter
   Fuel ConsumptionRICE (MMScf/hr) = Fuel consumption specified in the RICE manufacturer's specifications at 100% load rate
  Hours of Operation (hrs) = Operating Hours for each RICE, as read from the non-resettable hour meter.
   EFRICEeq   (lb/MMScf) = Equivalent emission factor for RICE without the natural gas consumption from the HVAC/Boilers/Heaters. It is calculated per equation in the below box:  


              EFRICEeq   =  EFRICE lbMMBtuxHV (MMBtuMMScf) - EFB/H lbsMMScf
              
                                            				
				EFRICE = NOx emission factor for natural gas fired RICE.                                                

                    HV = Heating value of the pipeline quality supplied natural gas (MMBtu/MMscf)
                 
                     EFRICEeq was calculated to be 2220.5 lb/MMscf for the EU-EG-09 (new natural gas fired RICE). Detailed calculation can be found in Appendix B of this document. 


Where, 

NOx emissions from Boilers&HVAC&Heating tons/month= EFB/H lbsMMScfxFNG MMScfx(1 ton/2000)........................................................................................................(1b)

                                                 
   EFB/H = NOx emission factor for uncontrolled Small Boilers (<100 MMBtu/hr).
     FNG  = the total amount of natural gas (MMscf/month) consumed by all NGCUs determined by summing the amounts derived from each of the four natural gas flow meters. Refer to Appendix A for the detailed list of all NGCUs.

Caution: Any major changes related to operating scenarios that can affect the federally enforceable permit conditions and that are not accounted for in the permit, need to be reported to EPA. EPA and MBCH will determine whether a permit modification is appropriate. Based on this determination, an application or letter of notification may need to be submitted to EPA. Major changes related to operating scenarios that can alter the permit limit and its related recordkeeping conditions, may include but are not limited to addition of a natural gas meter, addition of a new category of natural gas fired emission unit, and major changes in the operating scenarios. 

MBCH is required to comply with any applicable federal standards such as new source performance standards (NSPS) or air toxic (NESHAP and MACT) standards, as applicable to the site. 
      

8.	Control Technology Review for Proposed Modifications

Pursuant to 40 CFR 49.154(c), the EPA must conduct a case-by-case control technology review (CTR) to determine the appropriate level of pollution control for each pollutant subject to the Tribal Minor NSR Program to determine the appropriate level of control, if any, necessary to assure that the NAAQS are achieved. Through this case-by-case CTR, the EPA establishes emission limitations for the affected emission units at the proposed source. An emission limitation means a requirement established by the reviewing authority that limits the quantity, rate or concentration of emissions of air pollutants on a continuous basis, including any requirement relating to the operation or maintenance of a source to assure continuous emission reduction as well as any design standard, equipment standard, work practice, operational standard, or pollution prevention technique.

As stated in 40 CFR 49.154(c)(1), the case-by-case CTR considers the following four factors:

 Local air quality conditions.
 Typical control technology or other emissions reduction measures used by similar sources in surrounding areas.
 Anticipated economic growth in the area.
 Cost-effective emission reduction alternatives.

The proposed modifications at MBCH for the Laundry upgrade and HVAC/furnace upgrade projects are not subject to CTR because the PTE increase from the modifications did not trigger the requirement to get a permit. The permit is only being revised to keep the PTE limit accurate. Hence, no additional analysis of the control technology was needed for this permit modification process.


  8.1	Available Control Technologies for RICEs and Boilers

40 CFR 49.154(a)(2)(vii)  -  Existing control equipment and monitoring

Existing RICE at the site has the following control technology per NSPS/NESHAP standards controlling CO emissions. All RICEs below are non-emergency:

                                    EU-ID#
                              Source Description
                  Control Device(s) -  Pollutants Controlled
                Control Device Efficiency / Emission Standards 
                                   EU-EG-02
Diesel Fired RICE:
Detroit Diesel 16V149; 
Serial #: 16E0012327; 1800 rpm; 2-cycle; 16-cylinder; Rated Capacity: 2,340 hp (1,746 kW); 
Rated Heat Input: 16.6 MMBTU/hr; Rated Fuel Consumption: 121 gal/hr.

Installed in 1994
                           Oxidation Catalyst  -  CO
                     CO reduction >= 70% or limited to 23
                ppmv on a dry basis at 15% O2 per Subpart ZZZZ
                                   EU-EG-03
Diesel Fired RICE:
MTU Detroit Diesel 16V4000; 
Serial #: 5272002228; 1800 rpm; 16-cylinder; Rated Capacity: 
2,937 hp (2,190 kW); 
Rated Heat Input: 18.8 MMBTU/hr; 
Rated Fuel Consumption: 137 gal/hr.
 
Installed in 2005.
                           Oxidation Catalyst  - CO
CO reduction >= 70% or limited to 23 ppmv on a dry basis at 15% O2 per Subpart ZZZZ
                                   EU-EG-04
Diesel Fired RICE: 
MTU Detroit Diesel 20V4000; 
Serial #: 528100382; 1800 rpm; 4-cycle; 20-cylinder; 4.49 Liters per Cylinder; Rated Capacity: 4,036 hp (3,021 kW); Rated Heat Input: 26.2 MMBTU/hr; Rated Fuel Consumption: 191 gal/hr.

Installed in 2006
                           Oxidation Catalyst  -  CO
                     CO reduction >= 70% or limited to 23
                ppmv on a dry basis at 15% O2 per Subpart ZZZZ
        / NSPS Subpart IIII Table 1 standards for HC, NOx, CO, and PM,
                            per 40 CFR 60.4204(a).
                                   EU-EG-05R
Diesel Fired RICE: 
Cat 3516C; 
Serial #: LY600124; 78.1 Liters; 4.88 Liters per Cylinder; Rated Capacity: 2,941 hp (2,194 kW); 
Rated Heat Input: 19.1 MMBTU/hr; Rated Fuel Consumption: 140 gal/hr.

Installed in 2019
                    Selective Catalytic Reduction  -  NOx;
                                       
                           Oxidation Catalyst  -  CO
             Tier 4 standards for PM, NOx, NMHC(VOC), and CO, per
                 60.4201(a) and 40 CFR 1039.101 (Subpart IIII)
 
 
8.2	Consideration of the Four Factors of the Control Technology Review

The current permitting action of incorporating Project 1 (Laundry dryer upgrades) and Project 2 (HVAC/heating upgrades) into the existing synthetic minor permit does not require a review of the factors for control technology. The new emission units added in these projects do not have any associated control technology/device. 
      

8.3	Summary of Control Technology Review
 
In the current permitting action of incorporating Projects 1 and 2, no control device or control measures were applicable, hence, no review was necessary.

However, the new natural gas fired emergency RICE (EU-EG-09), from Project #2 is subject to NSPS Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, which means the hourly conditions for emergency operation is listed in 40 CFR 60.4243(d)(1) through (3) will apply and the new RICE shall be installed with a non-resettable hour meter to monitoring hours of use. More details on these federal regulations and applicable requirements can be found in www.ecfr.gov.  Besides NSPS Subpart JJJJ for the EU-EG-09, no new federal standards were triggered from Project 1 and 2, during this modification process. 

If the source should add or change equipment or change processes such that a NSPS or MACT subpart becomes an applicable requirement, then it is the source's obligation to comply with that subpart and applicable requirements regardless of whether they are identified in this permitting action.


9.	Air Quality Impact Analysis

9.1	Modeling Approach

Not applicable for this permit modification. 

9.2    AQIA Analysis Summary and Conclusion

The Air Quality Impact Analysis (AQIA) has not been reviewed for this permit modification process because the new emission units do not require a permit. EPA does not believe a modeling analysis is needed for this permit modification process because we believe that the project will not contribute to a National Ambient Air Quality Standard (NAAQs) or PSD increment violation. According to 40 CFR 49.154(d)(1) through (3), an AQIA may be required when the reviewing authority has reasons to be concerned about NAAQs or PSD violations.

Project 1 (Laundry Upgrade) replaces natural gas fired emissions units with a total capacity of 2.235 MMBtu/hr with 1.66 MMBtu/hr, which means there is net decrease of 0.58 MMBtu/hr capacity due to modifications. Thus, modeling analysis for this scenario was not necessary. For Project 2 (HVAC upgrades), the emission units being removed were have a rated heat input capacity of 1.28 MMBtu/hr while the new emission units are rated at 3.30 MMBtu/hr (total). Thus, there is a net increase of 2.02 MMBtu/hr due to the modification activities. Since the net increase is relatively minimal (~2.0 MMBtu/hr), EPA does believe that a modeling analysis of this minor source is necessary. Moreover, based on the 2022 Annual Compliance Certification by source, the reported emissions in relation to the facility-wide NOx 12-month rolling total was reported to be in the range of 10.46 to 14.29 tons per year (tpy), with a calculated average NOx of 12.00 tpy. Thus, the actual emissions were much lower than the major source thresholds.

       
 Listed Species-Related Requirements
                                       
Pursuant to section 7 of the Endangered Species Act (ESA), 16 U.S.C. 1536, and its implementing regulations at 50 CFR part 402, the EPA is required to ensure that any action authorized, funded, or carried out by the EPA is not likely to jeopardize the continued existence of any federally endangered (FE) or federally threatened (FT) species listed under the ESA, or result in the destruction or adverse modification of such species' designated critical habitat. The EPA has determined that this minor NSR permitting action for MBCH is subject to ESA section 7 requirements. In complying with its duty under the ESA, the EPA, as the action agency, examined the potential effects on listed species and critical habitat. 

Our analysis for this permit modification related to the laundry dryer and HVAC/heating replacement units will remain same as what is stated in the TSD document of 2019 issuance of original synthetic minor source permit which concludes that the permit action has "no effect" on the Indiana bat, northern long-eared bat, prairie bush-clover, and western prairie fringed orchid. As the lead federal agency for ESA Section 7(a)(2) compliance and given our determination that the proposed action will have "no effect" on listed species or critical habitat, EPA R7 is not consulting with the FWS Illinois-Iowa Ecological Services Field Office.
                  
National Environmental Policy Act (NEPA) Review: Under Section 793(c) of the Energy Supply and Environmental Coordination Act of 1974, no action taken under the Clean Air Act shall be deemed a major federal action significantly affecting the quality of the human environment within the meaning of the National Environmental Policy Act of 1969. The proposed permitting action is taken under regulations implementing the Clean Air Act and is therefore exempt from the NEPA. See Section 7(c) of the Energy Supply and Environmental Coordination Act of 1974, 15 U.S.C. 793(c) (1).


 Historic Properties-Related Requirements

Section 106 of the National Historic Preservation Act of 1966 (NHPA) requires federal agencies, including the EPA, to take into account the effects of an undertaking on historic properties. The implementing regulations of the NHPA can be found at 36 CFR part 800. An "undertaking," as defined at 36 CFR 800.16(y), includes projects requiring a federal permit. Therefore, the issuance of this permit constitutes an undertaking. 

The Village of Meskwaki Bingo Casino Hotel is located at 1504 305th Street, Tama, Iowa
52339 within the external boundaries of the Sac & Fox Tribe of the Mississippi in Iowa
(Meskwaki Nation) Indian Settlement. The EPA considered whether issuing the proposed synthetic minor permit might affect historic properties. The EPA searched the National Park Service National Register of Historic Places website and found one historic landmark located in Tama, IA. The Lincoln Highway Bridge is located on East 5th Street, Tama, IA.

The proposed permit modification action which involves incorporating the laundry dryer and HVAC replacements units into the existing synthetic minor permit does not authorize any emission increases from the existing units above the minor NSR thresholds in Table 1 of 40 CFR 49.153. The control technologies and enforceable permit limits established during the initial issuance of the synthetic minor source permit in 2019 (R7-TMNSR-2019-002), to limit MBCH's emission below the major source (Title V) thresholds, will remain the same for permit R7-TMNSR-2023-001. Thus, EPA considers this permit action the type of activity that does not have the potential to impact any historic properties.


 Environmental Justice (EJ) Analysis
         
Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," calls on each federal agency to make environmental justice a part of its mission by "identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies and activities on minority populations and low-income populations."

The EPA defines "Environmental Justice" (EJ) to include the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and polices. The EPA's goal is to provide an opportunity for overburdened populations or communities to participate in the permitting process. "Overburdened" is used to describe the minority, low-income, tribal and indigenous populations or communities in the United States that potentially experience disproportionate environmental harms and risks due to exposures or cumulative impacts or greater vulnerability to environmental hazards.

The EPA has developed an EJ mapping and screening tool called EJSCREEN. It is based on nationally consistent data and an approach that combines environmental and demographic indicators in maps and reports. 

No additional EJ screening analysis was performed for permit modification R7-TMNSR-2023-001, given the fact that the project specific emissions were less than the minor NSR thresholds in 40 CFR 49.153. Hence, EPA does not believe that any additional EJ screening was necessary to justify the project scope. Nevertheless, a full-scale EJ analysis was done during the 2019 initial synthetic permit issuance process. EPA has determined that further EJ analysis is not needed for these new projects focused for this modification permitting action, since the emissions are below minor source NSR review thresholds.


 Permit Content and Revisions

13.1   Permit Content and Revisions

The terms and conditions of the minor NSR permit are based on the required permit content and analyses specified in the Tribal Minor NSR Program. The required permit content for minor NSR permits is listed in 40 CFR 49.155  -  What information must my permit include? Below we describe the basis for the permit conditions.

General Requirements
40 CFR 49.155(a)(1) specifies the following elements that each minor NSR permit must include: the effective date of the permit and the date by which the owner/operator must commence construction for the permit to remain valid; the emissions units subject to the permit and their associated emission limitations; and monitoring, recordkeeping, and reporting requirements to assure compliance with the emission limitations. The revised permit includes these requirements.  

Emission Limitations
40 CFR 49.155(a)(2) states that each minor NSR permit must include the emission limitations determined by the reviewing authority under 40 CFR 49.154(c) for each affected emissions unit. The permit must also include annual allowable emissions limits for sources needing enforceable emission limitations to lower their potential to emit. 

40 CFR 49.154(c) provides that the reviewing authority must require a numerical limit on the quantity, rate, or concentration of emissions for each regulated NSR pollutant emitted by each affected emissions unit for which such a limit is technically and economically feasible. These emission limitations may consist of numerical limits on the quantity, rate or concentration of emissions; pollution prevention techniques; design standards; equipment standards; work practices; operational standards; requirements relating to the operation or maintenance of the source; or any combination thereof. The emissions limitations must assure that each affected emission unit will comply with all requirements of 40 CFR parts 60, 61, and 63, as well as any federal or tribal implementation plans that apply to the unit. Finally, the emissions limitations required may not rely on a stack height that exceeds good engineering practice or any other dispersion technique, except as allowed by 40 CFR 51.118(b).

Monitoring Requirements 
40 CFR 49.155(a)(3) provides that each minor NSR permit must include monitoring that is sufficient to ensure compliance with the emissions limitations that apply to the affected emissions units at a source. 

Recordkeeping Requirements							         
40 CFR 49.155(a)(4) provides that each minor NSR permit must include recordkeeping requirements sufficient to ensure compliance with the emission limitations and monitoring requirements. Additionally, the minor NSR permit must include the recordkeeping requirements in 40 CFR 49.155(a)(4)(i) and (ii), which require the source to keep records of certain information related to the monitoring requirements in the permit and to retain all required monitoring data and support information for at least 5 years. 

Reporting Requirements
40 CFR 49.155(a)(5) requires that each minor NSR permit include the reporting requirements listed in 40 CFR 49.155(a)(5)(i) and (ii) related to annual reports and reporting of deviations. 

Severability Clause
40 CFR 49.155(a)(6) provides that each minor NSR permit include a severability clause to ensure the continued validity of the other portions of the permit in the event of a challenge to a portion of the permit. The revised permit includes the required severability clause.

Additional Provisions
40 CFR 49.155(a)(7) requires that each minor NSR permit contain provisions stating the requirements in paragraphs (a)(7)(i) through (vii) of that section. The permit contains the required provisions. These conditions are found in the General Provisions section of the revised permit.

 Other Permit Revisions

The permit includes additional changes not described above. These include substantive changes to integrate conditions for the new equipment, as well as administrative changes such as updates to synchronize the permit language with the project updates. The summary of revisions done to the 2019 original synthetic minor source permit R7-TMNSR-2019-002 are given below:

Cover page 
    Language and formatting were updated to the most recent permit template. 

Section I  -  Facility Description
    Added Section (B) for the new project descriptions.
    Revised Section (C) emission unit tables with new and replacement units. 

Section II  -  Unit Specific Requirements
    Generalized permit language for RICE, without altering any enforceable conditions in Section (A).
    Removed hourly limits for RICE in Section (A), because all the RICE have the overall NOx emission limit for 12 months rolling totals. Furthermore, emergency RICE are regulated per MACT Subpart ZZZZ and NSPS Subpart JJJJ to operate for specific purposes within hourly limits, hence, this hourly limits of 695 and 1159 hours stated in the 2019 permit was redundant which makes the permit more robust without altering the enforceable permit limit.
    Revised the compliance NOx emission standard formula in (B) from all the NGCUs. The modified compliance formula is more robust to handle various type of emission units, burning natural gas at the site.
    Removed any specific gas meter # reference from section (B) (2) to make the permit language more robust. 

Section III  -  Facility wide Requirements 
    No changes when compared to permit R7-TMNSR-2019-002

Section IV- General Permit Requirements 
::    No changes when compared to permit R7-TMNSR-2019-002

Attachment A: NGCUs Descriptions
 Attachment A was deleted and the NCGUs description table is now in APPENDIX A. Table 2.0 of this document was removed from the permit and inserted into the TSD document. This allows the permit to be concise and more robust for future minor unit modifications/replacements, that do not necessarily need permit revisions. 

                                       
                                  APPENDIX A
       

Table 1.0  -  Emission Unit (EU) Descriptions for RICE

                                    EU-ID#
Source Description
                  Control Device(s) -  Pollutants Controlled
                Control Device Efficiency / Emission Standards 
                            Applicable Regulations*
                    RICE Location  -  Power Usage Location
                                   EU-EG-02
Diesel Fired RICE:
Detroit Diesel 16V149;
Serial #: 16E0012327; 1800 rpm; 2-cycle; 16-cylinder; Rated Capacity: 2,340 hp (1,746 kW);
Rated Heat Input: 16.6 MMBTU/hr; Rated Fuel Consumption: 121 gal/hr

Maximum Peaking rate of 300 hours/yr. 

Installation in 1994
                            Oxidation Catalyst  -  
                                      CO
                            CO reduction >= 70% or
                                 limited to 23
                                 ppmv on a dry
                       basis at 15% O2 per Subpart ZZZZ
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                           MACT Subpart A & ZZZZ
                                 Central Plant
                                   - Casino 2
                                   EU-EG-03
Diesel Fired RICE:
MTU Detroit Diesel 16V4000;
Serial #: 5272002228; 1800 rpm; 16-cylinder; Rated Capacity:
2,937 hp (2,190 kW);
Rated Heat Input: 18.8 MMBTU/hr;
Rated Fuel Consumption: 137 gal/hr.

Maximum Peaking rate of 300 hours/yr

Installed in 2005
                            Oxidation Catalyst  -  
                                      CO
                            CO reduction >= 70% or
                                 limited to 23
                                 ppmv on a dry
                       basis at 15% O2 per Subpart ZZZZ
                                       
                                 Central Plant
                                   - Casino 1
                                   EU-EG-04
Diesel Fired RICE:
MTU Detroit Diesel 20V4000;
Serial #: 528100382; 1800 rpm; 4-cycle; 20-cylinder; 4.49 Liters per Cylinder; Rated Capacity: 4,036 hp (3,021 kW); Rated Heat Input: 26.2 MMBTU/hr; Rated Fuel Consumption: 191 gal/hr
Maximum Peaking rate of 300 hours/yr.

Installed in 2006.
                            Oxidation Catalyst  -  
                                      CO
                            CO reduction >= 70% or
                                 limited to 23
                ppmv on a dry basis at 15% O2 per Subpart ZZZZ/
          NSPS Subpart IIII Table 1 standards for HC, NOx, CO, and PM
                             per 40 CFR 60.4204(a).
                                       
                                       
                          NSPS Subpart A & IIII;
                        MACT ZZZZ (applicability only)
                                 Central Plant
                                - Central Plant
                                   EU-EG-05R
Diesel Fired RICE:
Cat 3516C;
Serial #: LY600124; 78.1 Liters; 4.88 Liters per Cylinder; Rated Capacity: 2,941 hp (2,194 kW);
Rated Heat Input: 19.1 MMBTU/hr; Rated Fuel Consumption: 140 gal/hr.

Maximum Peaking rate of 300 hours/yr

Installed in 2019
                                       
                    Selective Catalytic Reduction  -  NOx;
                            Oxidation Catalyst  -  
                                      CO
              Tier 4 standards for PM, NOx, NMHC(VOC), and CO per
                   60.4201(a) and 40 CFR 1039.101  -  NSPS. 
                                       
                                       
                                       
                                       
                          NSPS Subpart A & IIII,
                                       
                    MACT Subpart ZZZZ (applicability only)
                                 Central Plant
                                    - Hotel
                                  EU-EG-EMERG
                                (Grouped units)
Three (3) emergency RICEs -diesel and natural gas (NG) fired. Combined rated capacity of 615 HP.

Details of the emergency RICE is given in Table 1.1, Appendix A. Per EPA guidance maximum emissions from emergency RICE is calculated based on 500 hours/yr, each RICE.

[Per 40 CFR 49.153(c)(9)(ii), emergency RICE with total maximum rated capacity < 1000 HP, is considered as exempt units from Tribal NSR permitting.]

                                       
                                     N.A.
                                       
                                 See Table 1.1
                                       
                                 See Table 1.1
                            Warehouse/Rec-Warehouse
                                       
                              East of GC Building
                                       
                               North Roof Tower
* RICE following requirements via NSPS Subpart IIII or JJJJ, hence is not subject to any additional requirements from MACT Subpart ZZZZ. They are complying with rules by following NSPS requirements as applicable. N.A. means not applicable. 






Table 1.1  -  Detailed descriptions of Emergency RICE (EU-EG-EMERG)


                                     EU-ID
                               (Collective Form)
                                    EU-IDs
                                  (Detailed)
                           Emission Unit Description
                                Control Device
                              Federal Regulations
                                   Location
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-EMERG
                                   EU-EG-06
Emergency Diesel Fired RICE:
Onan 125DGEA;
Serial #: A930497866; 1800 rpm; Rated Capacity: 207 hp (125 kW);
Rated Heat Input: 1.23 MMBTU/hr; Rated Fuel Consumption: 9 gal/hr

Installed in 1993
                                     N.A.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                          MACT Subpart A &  ZZZZ 
                                       
                                 Warehouse/Rec
                                       
                                   EU-EG-07
Emergency Diesel Fired RICE:
Onan 125DGEA;
Serial #: D940539338; 1800 rpm; Rated Capacity: 207 hp (125 kW);
Rated Heat Input: 1.23 MMBTU/hr;
Rated Fuel Consumption: 9 gal/hr

Installed in 1993
                                     N.A.
                                       
                      East of Gaming Commission Building 
                                       
                                   EU-EG-09
Emergency Natural Gas Fired RICE:
Kohler model # KG150, Rated Capacity: 150 KW, 1.919 MMBtu/hr.
This RICE is connected to natural gas meter # 1343357

Installed post 2022
                                     N.A.
                              NSPS Subpart JJJJ,
                                       
                    MACT Subpart ZZZZ (applicability only)
                              Roof of North Tower
N.A. refers to not applicable indicating no control devices for that RICE. For Emergency.


 Table 2.0  -  Detailed Description of Natural Gas Combustion Units (NGCUs)
 
 
                                 Grouped EU ID
                                     EU ID
                              EU Model, make, etc
                                 Installed Year
                                 EU Description
                                    Location
        NGCUs supplied by Gas Meter # 9743221 (Central Plant/Casino/RV)
 EU-NG-C1 through 
 EU-NG-C6
 (Several units at each location)
  EU-NG-C1
 
              Not specified  -  (collection of Food Cooking NGCUs)
                                        
                                       NA
                               Food Cooking NGCU
                                 Casino - Café
                                       
                                   EU-NG-C2



                             Casino  -  Food Court
                                       
                                   EU-NG-C3



                                Casino - Buffet
                                       
                                   EU-NG-C4



                              Casino - Steakhouse
                                       
                                   EU-NG-C5



                                Casino - Bingo
                                       
                                   EU-NG-C6



                               Casino - Banquet
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-CCP
                                   EU-NG-01
                         AAON
RK-25-3-40-232
98DKGP31
                                     1998
                             Roof HVAC-old kitchen
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                             Casino Central Plant
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    Casino
                                 Central Plant
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    Casino
                                 Central Plant
                                       
                                       
                                       
                                       
                                   EU-NG-02
                             Modine
QD122A
98-7875
                                     1998
                            Roof Make up air-café

                                       
                                   EU-NG-03
                           Raypak
WH3-0724
603248914
                                      NA
                            Domestic Boiler-Dish M.

                                       
                                   EU-NG-04
                   Thermal solution
EVA3000BNI-DCFM
65228842
                                     2011
                            HVAC Boiler 1East mezz

                                       
                                   EU-NG-05
                   Thermal solution
EVA3000BNI-DCFM
65228840
                                     2011
                            HVAC Boiler 2 east mezz

                                       
                                   EU-NG-06
                   Thermal solution
EVA3000BNI-DCFM
65228843
                                     2011
                            HVAC Boiler 3 east mezz

                                       
                                   EU-NG-07
                   Thermal solution
EVA3000BNI-DCFM
65228844
                                     2011
                            HVAC Boiler 4 east mezz

                                       
                                   EU-NG-08
                   Thermal solution
EVA3000BNI-DCFM
65228841
                                     2011
                            HVAC Boiler 5 east mezz

                                       
                                   EU-NG-09
                   Thermal solution
EVA3000BNI-DCFM
65228845
                                     2011
                            HVAC Boiler 6 east mezz

                                       
                                   EU-NG-10
                          Raypak
WH8-0992B
908300061
                                     2009
                            Domestic boiler -Bingo

                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-CCP
                                   EU-NG-11
                          Raypak
WH8-0992B
908300060
                                     2009
                            Domestic boiler -Bingo

                                       
                                   EU-NG-12
                        Lennox
LGA 060SHIG
5600C 08603
                                     2000
                              Roof top-HR Offices

                                       
                                   EU-NG-13
                        Lennox
LGA 060SHIG
5600C 05865
                                     2000
                              Roof top-HR Offices

                                       
                                   EU-NG-14
                        Lennox
LGA 060SHIG
5600C 08604
                                     2000
                              Roof top-HR Offices

                                       
                                   EU-NG-15
                              Lennox
LGA 060SHIG
                                     2000
                              Roof top-HR Offices

                                       
                                   EU-NG-16
                              Lennox
LGA 060SHIG
                                     2000
                              Roof top-HR Offices

                                       
                                   EU-NG-17
                        Lennox
LGA 060SHIG
5600C 03525
                                     2000
                              Roof top-HR Offices

                                       
                                   EU-NG-18
                        Lennox
KGA24054BSIG
5611DO8552
                                     2011
                            Roof top-South East EBR

                                       
                                   EU-NG-19
                      Lennox
GCS16-030-75-2P
5699H 10786
                                     2000
                             Roof top-Locker room

                                       
                                   EU-NG-20
                      Green Heck
IG-112-H20-DBC
10694771
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                   EU-NG-21
                      Green Heck
IG-112-H20-DBC
10694732
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                   EU-NG-22
                      Green Heck
IG-115-H30-DBC
10694729
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                   EU-NG-23
                      Green Heck
IG-113-H30-DBC
10694730
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                   EU-NG-24
                      Green Heck
IG-112-H20-DBC
10694733
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                   EU-NG-25
                      Green Heck
IG-112-H20-DBC
10694734
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                   EU-NG-26
                      Green Heck
IG-112-H20-DBC
10694735
                                    05-06?
                            Roof Top-Buffet Kitchen

                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                 EU EU-NG-CCP
                                   EU-NG-27
                        Reznor
UDAS45-S
EBFK79Y2N28037X
                                     2006
                          Heaters -F&B Warehouse

                                       
                                   EU-NG-28
                        Reznor
UDAS75-S
EBFK79Y2N29177X
                                     2006
                          Heaters -F&B Warehouse

                                       
                                   EU-NG-29
                        Reznor
UDAS75-S
EBFK79Y2N29175X
                                     2006
                          Heaters -F&B Warehouse

                                       
                                   EU-NG-30
                        Reznor
F125-E-S
EBIB65M4N90240X
                                     2006
                          Heaters -F&B Warehouse

                                       
                                   EU-NG-31
                        Reznor
F125-E-S
EBIB65M4N90238X
                                     2006
                          Heater s-F&B Warehouse

                                       
                                   EU-NG-32
                        Reznor
F125-E-S
EBIB65M4N90239X
                                     2006
                          Heaters -F&B Warehouse

                                       
                                   EU-NG-33
                        Reznor
F125-E-S
EBIB65M4N90237X
                                     2006
                          Heaters -F&B Warehouse

                                       
                                   EU-NG-39
                          Rapid Air
8500-100HBL
59064
                                     2015
                              Roof MAU corridors
                                   S. Tower

                                       
                                       
                                       
                                       
                                  EU-NG-CMEC
                                   EU-NG-40
                       Thermal solution
APX725C
65611858
                                     2017
                           Domestic Boiler S. Tower
                                Casino Old Mech
                                       
                                       
                                   EU-NG-41
                       Thermal solution
APX725C
65618999
                                     2017
                           Domestic Boiler S. Tower
                                       
                                       
                                   EU-NG-42
                       Thermal solution
APX725C
65633764
                                     2017
                           Domestic Boiler S. Tower
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-CCP
                                   EU-NG-43
                 Thermal solution EB2
EVS0500BN-1-UFC
65511810
                                   6/1/2015
                                  HVAC Boiler
                                       
                                       
                                       
                                    Casino
                                 Central Plant
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    Casino
                                 Central Plant
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-44
                 Thermal solution EB1
EVS0500BN-1-UFC
65511809
                                   6/1/2015
                                  HVAC Boiler

                                       
                                   EU-NG-45
                    AO Smith Preferred
BT 65 100
F05A031745
                                   6/7/2015
                            Water heater 65-gallon

                                       
                                   EU-NG-46
                  Vantage EV Roberts
EV-80
0604-051-080-0002
                                    b-2004
                                Radiant-Auto 1

                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-CCP
                                   EU-NG-47
                  Vantage EV Roberts
EV-80
0604-051-080-0001
                                    b-2004
                                Radiant-Auto 2

                                       
                                   EU-NG-48
                  Vantage EV Roberts
EV-110
0604-051-110-0001
                                    b-2004
                                Radiant-Auto 3

                                       
                                   EU-NG-49
                  Vantage EV Roberts
EV-170
0604-051-170-0003
                                    b-2004
                                Radiant-Auto 4

                                       
                                   EU-NG-50
                  Vantage EV Roberts
EV-110
0604-051-110-0002
                                    b-2004
                                Radiant-Wood 1

                                       
                                   EU-NG-51
                  Vantage EV Roberts
EV-110
0604-051-110-0001
                                    b-2004
                                Radiant-Wood 2

                                       
                                   EU-NG-52
                  Vantage EV Roberts
HE-100
0604-032-100-0004
                                    b-2004
                              Radiant-Wash Bay 1

                                       
                                   EU-NG-53
                  Vantage EV Roberts
HE-100
0604-032-100-0002
                                    b-2004
                              Radiant-Wash Bay 2
                             Casino Central Plant
                                       
                                   EU-NG-54
                         Reznor
UDAS75
BFE79X7N94419X
                                    May-06
                                 Heaters-Crib
                                     -down

                                       
                                   EU-NG-55
                          Reznor
UDAS75
Assumed same
                                    May-06
                             Heaters-Crib-upstairs

                                       
                                   EU-NG-56
                        Lennox
G26Q4/5-75-6
5802F 29908
                                      NA
                               Furnace-woodshop

                                       
                                  EU-NG-92**
                   Continental Girabau, Model no. CG165-175
                                     2022
                              New Laundry Dryer 1
                                 Hotel Laundry
                                       
                                  EU-NG-93**
                   Continental Girabau, Model no. CG165-175
                                     2022
                              New Laundry Dryer 2
                                 Hotel Laundry
                                       
                                  EU-NG-94**
                   Continental Girabau, Model no. CG165-175
                                     2022
                              New Laundry Dryer 3
                                 Hotel Laundry
                                       
                                  EU-NG-95**
                    Continental Girabau, Model no. CP32130S
                                     2022
                               Compact 5-in-one
                                 Hotel Laundry
Combined NG Flow rate for all the NGCUs supplied by Gas Meter # 9743221 = 0.04 MMScf/hr
        NGCUs connected to Gas Meter # 1343357 (Hotel  -  North Tower)
                                   EU-NG-NT
                                   EU-NG-57
                   Thermal solution
EVS2000BN1-UEF
65511816
                                     2015
                                Boiler 1 Hotel
                                       
                               Hotel-North Tower
                                       
                                       
                                       
                                       
                                       
                               Hotel North Tower




















EU-NG-NT

                                   EU-NG-58
                   Thermal solution
EVS2000BN1-UEF
65511817
                                     2015
                                Boiler 2 Hotel

                                       
                                   EU-NG-59
                   Thermal solution
EVS2000BN1-UEF
65511815
                                     2015
                                Boiler 3 Hotel

                                       
                                   EU-NG-60
                       Laars
PNCV0750NACK2BJN
C06167073
                                     2007
                             Domestic Boiler-Hotel

                                       
                                   EU-NG-61
                       Laars
PNCV0750NACK2BJN
C06167140
                                     2007
                             Domestic Boiler-Hotel

                                       
                                   EU-NG-62
                    Pool Pak
SWHP080-10E-A02-R22
PPK060608
                                     2007
                                     Pool

                                       
                                   EU-NG-63
                         Raypak
C-R406A-EN-C
607254003
                                     2007
                                  Pool Boiler

                                       
                                   EU-NG-64
                         Raypak
C-R206A-EN-C
606253027
                                     2007
                                  Spa Boiler

                                       
                                   EU-NG-65
                        Slate
SBD8536NEA 118
AO7M003247
                                     2007
                               Spa Water Heater

                                       
                                   EU-NG-66
                             Lennox
MPD3530CPM
NA
                                     2007
                           Hotel Fireplace Room 959
                               Hotel-North Tower
                                       
                                       
                                   EU-NG-67
                             Lennox
MPD3530CPM
NA
                                     2007
                           Hotel Fireplace Room 959

                                       
                                   EU-NG-68
                             Lennox
MPD3530CPM
NA
                                     2007
                           Hotel Fireplace Room 960

                                       
                                   EU-NG-69
                             Lennox
MPD3530CPM
NA
                                     2007
                           Hotel Fireplace Room 960

                                       
                                   EU-NG-70
                               Lennox
EDVPFPM
NA
                                     2007
                           Hotel Fireplace Room 977

                                       
                                   EU-NG-71
                       Reznor
RDF-1-20-3
G82V1NO2490CAMV
                                     2009?
                             N. Tower MAU S. stair

                                       
                                       
                                   EU-EMERG
                                       
                                       
                                       
                                   EU-EU-09
         Kohler model # KG150, Rated Capacity: 150 KW, 1.919 MMBtu/hr.
                                       
                                     N.A.
                      Emergency RICE, Natural Gas fired.
                              NSPS Subpart JJJJ,
                       Subpart ZZZZ (applicability only)
Roof of North Tower
Combined NG Flow rate for all the NGCUs supplied by Gas Meter # 2199577 = 0.01 MMScf/hr
  NGCUs connected to Gas Meter # 450057898 (East Building/Gaming Commission)
                                       
                                   EU-NG-83
                      Nortek Global
UDAP-75
BPC3062019255
                                     2017
                               Heater -old Auto
                                 East Building
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-RT
                                  EU-NG-96**
                Reem Manufacturer; model no. RGEDZ5090ACB20BAA
                                     2022
                                     HVAC
                               NE Roof Top Unit
                                       
                                  EU-NG-97**
                Reem Manufacturer; model no. RGEDZ5090ACB20BAA
                                     2022
                                     HVAC
                              NW Roof Topic Unit
                                       
                                  EU-NG-98**
                Reem Manufacturer; model no. RGEDZ5090ACB20BAA
                                     2022
                                     HVAC
                              SW Roof Topic Unit
                                       
                                  EU-NG-99**
                Reem Manufacturer; model no. RGEDZ5090ACB20BAA
                                     2022
                                     HVAC
                               SE Roof Top Unit
                                       
                                  EU-NG-100**
                 Reem Manufacturer; model no. W95TC0601317MSA
                                     2022
                                     HVAC
                                SW 2[nd] Floor
                                       
                                  EU-NG-101**
                 Reem Manufacturer; model no. W95TC0601317MSA
                                     2022
                                     HVAC
                                SW 2[nd] Floor
                                       
                                  EU-NG-102**
                 Daikin Manufacturer, model no. DM96VC0804CNAA
                                     2022
                                     HVAC
                           Printshop S. 2[nd] Floor
                                       
                                  EU-NG-103**
                 Reem Manufacturer; model no. W95TC0701317MSA
                                     2022
                                     HVAC
                                NE 1[st] Floor
                                       
                                  EU-NG-104**
                 Reem Manufacturer; model no. W95TC0701317MSA
                                     2022
                                     HVAC
                                NW 2[nd] Floor
                                       
                                  EU-NG-105**
                 Reem Manufacturer; model no. W95TC0701317MSA
                                     2022
                                     HVAC
                                   NW 2[nd]
                                     Floor
                                       
                                  EU-NG-106**
                 Reem Manufacturer; model no. W95TC0701317MSA
                                     2022
                                     HVAC
                                NE 1[st] Floor
Combined NG Flow rate for all the NGCUs supplied by Gas Meter # 9527284= 3.30 E-04 MMScf/hr
              NGCUs connected to gas meter # 96216023 (Warehouse)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-NG-WH
                                   EU-NG-84
                       Solaronics
STG-150-60CN
ST-0 1668
                                     2000
                               Radiant Heater 1
                                       
                                 Warehouse/REC
                                       
                                   EU-NG-85
                       Solaronics
STG-150-60CN
ST-0 1667
                                     2000
                               Radiant Heater 2

                                       
                                   EU-NG-86
                       Solaronics
STG-150-60CN
ST-0 1666
                                     2000
                               Radiant Heater 3

                                       
                                   EU-NG-87
                       Solaronics
STG-150-60CN
ST-0 1671
                                     2000
                               Radiant Heater 4

                                       
                                   EU-NG-88
                       Solaronics
STG-150-60CN
ST-0 1669
                                     2000
                               Radiant Heater 5

                                       
                                   EU-NG-89
                        Lennox 
GHR26Q3-75-7
5800A42814
                                     2000
                                 south-office

                                       
                                   EU-NG-90
                         Lennox
CB29M-65-1P
5802J06580
                                     2000
                                 fire storage
                                 Warehouse/REC
                                       
                                       
                                   EU-NG-91
                        Lennox
GhHR26Q3-75-7
5800J22263
                                     2000
                                  Purchasing
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Combined NG Flow rate for all the NGCUs supplied by Gas Meter # 96216023 = 9.46E-04 MMScf/hr
Combined NG Flow rate through all the four meters at the site= 0.05 MMScf/hr
*NA means not available/applicable or unknown.
** Installed during 2023 Administrative Amendment of the permit

                                  APPENDIX B
                                       
Details for Equations 1, 1(a) and 1(b), related to NOx emission calculations from all NGCUs.
                                       
NOx Emissions (tons/month) (all NGCUs) = 

[NOx emissions from natural gas fired RICE] + [NOx emissions from natural gas fired Boilers/HVAC/Heating] (tons/month)......................................................................................................................... (1)


Where, 
NOx emissions from natural gas fired RICEs tonsmonth= 
i=1nEFRICEeq lbMMScfx Fuel ConsumptionRICEMMScfhrxHours of OperationRICE hrx(1 ton2000)..................................................................................................................(1a)

                             
   n = no. of RICE at the site connected to natural gas meter
  Fuel ConsumptionRICE (MMScf/hr) = 1873 SCF/hr (stand. Cubic feet/hr) or 0.001873 MMscf/hr, based on manufacturer specification sheet for EU-EG-09 (new natural gas fired RICE, Kohler, Model KG150 at 60 Hz (Hertz) and at 100% load capacity.
  Hours of Operation (hrs) = Operating Hours for each RICE, as read from the non-resettable hour meter.
   EFRICEeq   (lb/MMScf) = Equivalent emission factor for RICE without the natural gas consumption from the HVAC/Boilers/Heaters. It is calculated per equation in the below box:  

              EFRICEeq   =  EFRICE lbMMBtuxHV (MMBtuMMScf) - EFB/H lbsMMScf
              
               EFRICE = 2.21 lb/MMBtu (from AP-42, Table 3.2-3 for 4 Stroke Rich Burn RICE at 95-105% load rate NOx emission factor)  HV = 1050 MMBtu/MMscf (heating value of natural gas assumed)
             EFB/H = 100 lbs/MMScf (from AP-42, Table 1.4-1, for small boilers NOx emission factor)
                                                                            Thus,        EFRICEeq  = [2.21 x 1050 ] - [100]
                                                                                                              = [2320.5-100]
							              = 2220.5 lb/MMscf
  
              NOTE: The equivalent emission factor for RICE was needed to prevent overestimation/double counting of NOx emissions of non-RICE units, from the same gas meter #1343357 which is both connected to RICE and other non-RICE units. Non-RICE units per AP-42 has emission factor for NOx as 100 lb/MMscf. Thus, using emission factor directly from AP-42 for RICE will overestimate by 100 lb/MMscf and equivalent NOx emission factor is needed for RICE routed to the same gas meter.  Thus, EFRICEeq    was estimated, that can be used in equation 1a, to calculate NOx emissions from RICE only, based on Hours of operation. Non-resettable hour meter associated with each RICE, enables us to calculated NOx emissions more relevantly based on hours of operations. On the other hand, the AP-42 RICE emission factor has not been updated since 2000 and since the new RICE is built to comply with newer emission standards it is reasonable to judge that any underestimation is avoided in using equivalent emission factor for RICE. Also, a fuel consumption rate (1873 MMScf/hr) was used at 100% load which is worst case scenario for this emergency RICE.

	Since it is not possible to estimate how much fraction of natural gas consumption through gas meter#1343357 will be from the operation of RICE and non-RICE units, an average emission factor between RICE and non-RICE units will not reflect the correct scenario. Therefore, EFRICEeq was calculated as the best estimate for emission factor, in case of any gas meter that is connected to both RICE and non-RICE units.









Where, 

NOx emissions from Boilers&HVAC&Heating tons/month= EFB/H lbsMMScfxFNG MMScfx(1 ton/2000)........................................................................................................(1b)
                                                 
   EFB/H = NOx emission factor for uncontrolled Small Boilers (<100 MMBtu/hr) (from AP-42, Table 1.4-1).
     FNG  = the total amount of natural gas (MMscf/month) consumed by all NGCUs determined by summing the amounts derived from each of the four natural gas flow meters. Refer to Appendix B, for the detailed list including the natural gas RICE at the site.





                                  APPENDIX C
                                       
REVISED red line strikeout version of the 2019 permit edits via Microsoft Word Compare Tool Function- See attached file.
                                       
                                       
                                       
